STATE’S MOTION TO MODIFY OR REVOKE BOND The State of Florida, by and through the undersigned Assistant State Attorney, hereby moves this Honorable Court for an Order Revoking Defendant’s bond in the instant case. In support of the instant Motion, the State submits the following: (1) On November 27, 2013, Defendant was released by this Court on bond in the instant case, with the Court noting that it was “not this court’s customary practice to allow continued pretrial release for defendants who commit a crime while they are out on bond awaiting trial” (as Defendant had done). Defendant was given a series of special conditions, which the court called “stringent,” most notably including the provision that Defendant (paragraph #4) “remain on home detention.... and will not be allowed to leave her residence except for court appearances, medical emergencies, and to satisfy any requirements” of her pretrial services programs (such as providing a drug test). (2) Beginning December 6, 2013 (mere days after being released), and continuing on multiple dates (December 6, twice on Dec. 9, Dec. 12, 13, 15, 16, 17, 18, and Dec. 20, 2013) (nine days in a 14day span), Defendant repeatedly flouted the above-referenced conditions. She did so in order to, inter alia, go shopping for clothes; ferry family members to and from such places as the hair shop and airport; -1C:\Users\difranza\AppData\Local\Microsoft\Windows\Temporary Internet Files\Content.Outlook\3BQSVIXJ\Alexander Revoke.doc

3d DCA 2004). Roth. 277 B. get new glasses. then it must enforce its own orders. 2 . “The object of bail in a criminal case is to put the accused as much under the power of the court as if he were in custody of the proper officer. Defendant neither sought nor obtained permission from the Court for any of the above.D. 755. Defendant was granted bond once before. E. During one such sojourn.visit the bank. get a new driver’s license. 759 (Bankr. and travel to the office of a former attorney. rather. Defendant went to the residence of the brother of the victim in this case. Defendant is once again violating the Court’s orders. In re Malmgren.” Hernandez v.2d 1173 (Fla. Defendant has not submitted herself to the power of the Court. if a party is to be able to place any justifiable reliance on an order.R. get estimates for getting her vehicle repaired. 2002). and violated the Court’s order on multiple occasions– whereupon the Court revoked it. Wis. if a court is to have any credibility and command any respect. If an order is to have any true meaning. she continues to demonstrate her utter disregard for conforming her behavior to the rules others (including other Defendants granted bond by the courts) must abide by. and this Court should not continue to allow itself to be disrespected in such blatant fashion. 890 So. collect funds to give to her bond agent.

. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a copy of the foregoing motion has been furnished to Bruce Zimet. Bar Number 119296 3 . Attorney for Defendant. ANGELA B. 2014. Mantei Assistant State Attorney Fla. this __th day of January. Esq. Respectfully submitted. the state requests this Honorable Court revoke Defendant’s bond (again) in the instant case.WHEREFORE. COREY STATE ATTORNEY By:___________________________________ Richard W.

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